Adiarte v. Domingo
REITERATIONFacts
The Antecedents: On March 22, 1928, an action (Civil Case No. 3011) was instituted for the recovery of P1,150, the price of lumber, alcohol, and shellac, which the defendant allegedly obligated himself to deliver to the plaintiff. The plaintiff's defense was non-delivery, but judgment was rendered against him, which was affirmed by the Supreme Court. Upon execution, the plaintiff's real property was sold at public auction. Procedural History: One year later, on October 17, 1936, the plaintiff filed a new action to compel the defendant to deliver the same goods. A demurrer based on res adjudicata was sustained by the trial court. This order was affirmed by the Supreme Court, with a modification allowing the plaintiff to amend his complaint. On June 3, 1939, the plaintiff filed an amended complaint, but it did not plead any new facts to constitute a proper cause of action. A second demurrer, again on the ground of res adjudicata, was sustained by the trial court. The Petition: The plaintiff appealed the order dismissing his amended complaint.
Issue(s)
Whether the trial court erred in sustaining the second demurrer on the ground of res adjudicata. Whether the trial court erred in taking judicial notice of the records in Civil Case No. 3011.
Ruling
The Supreme Court affirmed the order of the trial court dismissing the amended complaint.
Ratio Decidendi
On the issue of res adjudicata and the amended complaint: The Court reiterated that res adjudicata was expressly declared in its previous judgment affirming the order sustaining the demurrer to the plaintiff's original complaint. Since the amended complaint introduced no new facts to constitute a proper cause of action, the prior declaration of res adjudicata must necessarily control the matter of the amended complaint. The principle of res adjudicata bars the re-litigation of issues that have already been passed upon and decided by a competent court. The amended complaint, by failing to introduce new material facts, did not overcome the effect of the prior judgment. Therefore, the subject matter and the issues presented were deemed settled by the previous litigation. On the issue of judicial notice: The Court clarified that the trial court did not err in taking judicial notice of the records in Civil Case No. 3011. The Court referred to its previous judgment of affirmance, which acknowledged that the lower court could not but take into account the existence and outcome of Civil Case No. 3011, as the complaint itself referred to it. Furthermore, the Court cited its own ruling in U.S. vs. Claveria, stating that in the absence of objection and for convenience, a court may properly treat parts of the original record of a former case as read into the record of a pending case when reference is made to it with the knowledge of the opposing party. This practice is permissible to avoid unnecessary duplication and to ensure judicial efficiency.
Main Doctrine
A second demurrer based on res adjudicata will be sustained if an amended complaint fails to introduce new facts constituting a proper cause of action, as the prior declaration of res adjudicata remains controlling.